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Editor-in-chief: Johanna Salomaa-Valkamo

Editor: Päivi Jokiniemi

Article related to: People and perspectives

From substitution to safe design

With Europe aiming to transition towards a circular economy and a non-toxic environment, one contribution to this goal is coming from the Netherlands’ Safe Chemicals Innovation Agenda. The agenda highlights research needs that, if met, will accelerate the safe design of chemicals, materials and products. We spoke with Dr Jochem van der Waals, a Senior Policy Advisor at the Dutch Ministry of Infrastructure and Water Management to find out more.

The Safe Chemicals Innovation Agenda outlines areas of research that, if taken on board by scientists, technicians, businesses and policy makers, could play a greater role in accelerating the safe design of chemicals, materials and products.

The concept of safe by design aims to address safety issues during the research and development, and design phases of production. This is done to reduce the need for substitution at a later stage.

Designing for safety has become increasingly popular for addressing risks in emerging fields such as nanotechnology and synthetic biology, and it is hoped that the methods developed to assess and reduce risks during the design stage could also be adopted for chemicals.

Jochem van der Waals. Image: Cefic.

“More innovation is needed to develop safe chemicals, materials and products and this needs toxicity to be understood and taken into account at the design stage,” Dr van der Waals says.

“It’s not just about looking for like-for-like chemical replacements, which are not always necessarily much safer. For instance, instead of looking to replace bisphenol A with other bisphenols such as bisphenol S, the agenda promotes looking at the technical and scientific requirements for the chemical’s use. We push research to ask whether we really need to print out our till receipts on thermal paper or whether there might be technological and more environmentally-friendly solutions,” he explains.

Priority areas for research and development

The agenda outlines seven priority areas where research and development could have an impact on EU and national policy and stimulate safe design. These areas are:

Plasticisers – developing alternatives without adverse effects on reproduction or endocrine activity. Such solutions could be alternative chemicals or materials.

Solvents – most solvents are volatile organic compounds, and developing alternatives could mean substantial reformulation and production process changes.

Surfactants – some surface-active agents are known or suspected endocrine disrupting chemicals. Here research is needed on their molecular behaviour and on production scale up.

Curing agents – research is needed to overcome technical barriers to effective substitution of hazardous curing agents used during polymerisation to strengthen resins, rubbers and foams.

Other avenues for research were also identified including fertilisers, pesticides, energy storage, surface protection, methodologies for assessing alternatives and legacy contamination.

“We hope that the agenda will inspire the European Commission and Member States to take up these areas for research as an input to Horizon Europe, the next research and innovation framework programme that will succeed Horizon 2020,” Dr van der Waals explains.

“We are also engaged at national level with many research institutes and are encouraging them to concentrate their research on these areas”.

From substitution to safe design

While progress has been made to reduce the use of harmful chemicals in Europe, thanks to regulations like REACH, Dr van der Waals feels that there are limits to what can be achieved with legislation.

“Regulatory requirements are not sufficient on their own, because we have seen that substitutes are often drop-in replacements and not necessarily safer,” Dr van der Waals says.

“The shift towards safe design is also essential to achieve a circular economy. Avoidance of toxic chemicals enables safe recycling and reuse of materials, including in new life stages that are unknown at the design stage,” Dr van der Waals tells. In January 2018, ECHA launched its substitution strategy with a focus on the functionality of chemicals. “Moving to safer chemicals, materials and products should begin by considering what functions are needed, rather than just managing a chemical’s risks,” highlights Dr van der Waals.

“Considering the function of a substance rather than its chemical structure and risks would allow a wider range of substitution solutions to be available.“

Supply chain approach

The challenges in moving towards safer chemicals, materials and products are different depending on the products and specific supply chains involved.

“There is an economic barrier. Substitution can be costly, with uncertain results and high failure rates. Chemical companies have often invested heavily in their chemicals and associated production lines, and are reluctant to change until they get a return on their investment,” Dr van der Waals says.

It is also not always clear what a safe product is or what will be sustainable. “When you replace a chemical, you need to be able to ensure that the replacement is safer and assessing this can be difficult.”

A very important aspect is that for substitution to work, there needs to be effective communication and cooperation throughout the supply chain.

“You have to bring together the end users of products, chemical industry or suppliers of alternative materials, and all the actors in between," Dr van der Waals says.

"An important question is what exactly are the end-user requirements. The chemicals industry is not used to dealing with end users.

With existing products, the supply chains generally know how to deal with them, but with new products, there is a greater need for the supply chain to adapt,” he adds.

There are ways to overcome this, such as when there are downstream user companies with a strong market position that demand safer products. There are good examples of this in textiles and electronics.

The presence of a neutral facilitator can also help, and this is also the idea behind the substitution workshops that fit into ECHA’s strategy.

Piloting the approach

The Netherlands has piloted this approach in a recent international workshop about safe and sustainable antifouling products for recreational craft.

There is also a need for a stronger connection between chemicals policy and innovation policy both at Member State and EU level.

“Cooperation between ministries and institutions is not commonplace, and it should be encouraged,” Dr van der Waals tells.

Dr van der Waals is a Senior Policy Advisor working in the asbestos, biocides and chemicals team at the Dutch Ministry of Infrastructure and Water Management.

The team operates within a larger directorate that deals with environmental safety and risks. The work of the team sees them involved in different aspects of chemicals policy including REACH, the Biocidal Products Regulation, the Persistent Organic Pollutants Regulation as well as substitution and innovation.

Bio-based alternatives

Within some of the research areas in the agenda, such as plasticisers, solvents and surfactants, bio-based alternatives may offer a viable solution.

A report from Wageningen Food & Biobased Research commissioned by the Dutch National Institute for Public Health and the Environment (RIVM) has revealed a number of promising bio-based alternatives to the polar aprotic solvents NMP, DMAc and DMF.

A broad scan of new and marketable bio-based chemicals was carried out focusing specifically on substitutes for the three solvents – since they are substances of very high concern (SVHCs). Their use may be limited under EU chemicals legislation in the future.

Within the EU project RESOLVE, Wageningen Food & Biobased Research is already developing safer alternatives to toluene and NMP. RESOLVE focuses on developing alternatives with a completely different chemical structure, entirely avoiding the chemical groups which make toluene and NMP toxic.

The alternatives are also deemed to be sustainable because they are made from carbohydrate-rich waste streams such as sugar beet pulp.

The European Commission has published its proposal for Horizon Europe, an ambitious €100 billion research and innovation programme that will succeed Horizon 2020.

Horizon Europe will incorporate policy missions to ensure the effectiveness of research and innovation funding by pursuing clearly defined targets. This approach to policy making will set defined goals, with specific targets and working to achieve them in a set time.

Instead of looking for like-for-like chemical replacements, there may be more environmentally-friendly solutions. So, instead of replacing a substance like bisphenol A with other bisphenols, research should consider whether BPA-covered thermal paper should be used for till receipts or if there is a technological solution. Image: iStock.com/maica.